shearon harris, units 2 and 3, response to u.s. army corps

Progress Energy

Serial: NPD-NRC-2010-074September 22,2010

U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, D.C. 20555-0001

SHEARON HARRIS NUCLEAR POWER PLANT, UNITS 2 AND 3DOCKET NOS. 52-022 AND 52-023RESPONSE TO U.S. ARMY CORPS OF ENGINEERS REVIEW COMMENTS ON SECTION404(b)(1) - ALTERNATIVES ANALYSIS REVISION 1

Reference: Letter from Donald Palmrose (NRC) to John Elnitsky (PEC), dated April 20, 2010,"Transmittal of U.S. Army Corps of Engineers'Review Comments on Revision 1 ofHarris Advanced Reactor Section 404(b)(1) - Alternatives Analysis"

Ladies and Gentlemen:

Progress Energy Carolinas, Inc. (PEC) hereby submits our response to the U.S. Army Corps ofEngineers (USACE) and U.S. Environmental Protection Agency (EPA) comments provided in thereferenced letter. This response answers the USACE and EPA comments from their review of the"Harris Advanced Reactor (HAR) Section 404(b)(1) Alternatives Analysis, Revision 1."If you have any further questions, or need additional information, please contact Bob Kitchen at

(919) 546-6992, or me at (727) 820-4481.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 22, 2010.

Sir

Vice PresidentNew Generation Programs & Projects

Enclosure/Attachments

cc: U.S. NRC Region II, Regional AdministratorU.S. NRC Resident Inspector, SHNPP Unit 1Mr. Brian Hughes, U.S. NRC Project ManagerDr. Donald Palmrose, U.S. NRC Environmental Project ManagerMr. Monte Matthews, U.S. Army Corps of Engineers

Progress Energy Carolinas, Inc.PO. Box 1551Raleigh, NC 27602

okQ

Enclosure to Serial: NPD-NRC-2010-074Page 1 of 21

Shearon Harris Nuclear Power Plant Units 2 and 3Response to Review Comments on Section 404(b)(1) Alternatives Analysis, Revision 1,

for the Combined License Application, dated April 20, 2010

NRC RAI #

NA

Progress Energy RAI #

H-0612 & H-0622

Progress Energv Response

Response enclosed - see following pages


NRC Letter: Review Comments on Alternatives Analysis

NRC Letter Date: April 20, 2010

NRC Review of Environmental Report

USACE Action ID Number: SAW-2007-01748

USACE Letter Date: April 15, 2010

PGN RAI ID #: H-0612 and H-0622

Progress Energy Carolinas, Inc. (PEC) provides the below responses to the comments,concerns, and requests for clarification and additional information in the U.S. Army Corps ofEngineers (Corps) letter dated April 15, 2010, which included an attached letter from U.S.Environmental Protection Agency (EPA) dated March 19, 2010. Responses have beenprovided for the general and specific comments included in the letter concerning the documentsentitled "Harris Advanced Reactor (HAR) Section 404(b)(1) Alternatives Analysis (Revision 1)"dated September 2009, and "Technical Memorandum 107, Determination of Harris ReservoirStorage Requirements, Revision 1" dated September 9, 2009.

Corps Comments:

1. Comment: "Please reference the additional information provided by Progress Energy inresponse to our letter dated June 19, 2009. This information was contained within thedocuments entitled "Harris Advanced Reactor Section 404 (b)(1) Alternatives AnalysisRevision 1" dated September 2009, and "Technical Memorandum 107, Determination ofHarris Reservoir Storage Requirements, Revision 1" dated September 2009. Thesedocuments support the proposal by Progress Energy Carolinas, Inc. (PEC) to create newsources of electricity in and around North Carolina. PEC's preferred alternative for this is toexpand the Shearon Harris Nuclear Power Plant by adding two new reactors. The U.S.Army Corps of Engineers (Corps) is acting as a cooperating agency, with the NuclearRegulatory Commission (NRC) acting as the lead agency in development of anEnvironmental Impact Statement under the National Environmental Policy Act (NEPA). Wesupplied both documents to the United States Environmental Protection Agency (EPA) forcomments. Please find the EPA's letter attached for your consideration. In addition, weoffer the following comments to ensure the decision document contains all aspects requiredby NEPA and the Corps 404 (b)(1) Guidelines."

Response: Acknowledged. Responses to the Corps' comments are provided herein.Responses to EPA's letter are provided following responses to the Corps letter. To facilitatereview, Corps comments are numbered 1 through 16, and EPA comments are numbered 17through 30.

2. Comment: "The first document is the "Technical Memo 107" (TM 107) which details theapplicant's proposal to raise the normal pool of Harris Lake from 220 MSL to 240 MSL.Because this component comprises the majority of impacts associated with the Harrisalternative, any minimization measure to the proposed water level increase could protect asubstantial amount of aquatic resources. The attached EPA letter requests several validitems for review and clarification and requests that the North Carolina Division of WaterResources staff review the TM 107 and the supporting information for concurrence with the


assumptions and model results. We agree and believe that coordination with the state willprovide a level of assurance with this approach and may find ways to minimize this portionof the alternative. In short, we believe that further exploration of lower pool levels may benecessary before the Corps can concur that a 240 MSL elevation is the minimumpracticable pool level for the project."

Response: A revised TMEM-107 is attached to this response. The revised TM providesadditional information on cooling water requirements for the HAR2 and HAR3 andalternative operating pool levels. The information in TMEM-107 demonstrates that anoperating level of 240 feet National Geodetic Vertical Datum of 1929 (NGVD29) is requiredto meet the purpose and need of the project, providing continued reliable power generationfrom the three units, while minimizing impacts to water resources in the Cape Fear RiverBasin.

PEC provided TMEM-107 to the North Carolina Division of Water Resources (NCDWR) forreview in June 2010 and engaged NCDWR in a discussion of the methodology and resultsof the lake level analysis. NCDWR comments and suggestions were incorporated in therevised analysis.

3. Comment: "The second document, "Harris Advanced Reactor Section 404 (b)(1)Alternatives Analysis Revision 1" (Alternatives, revl) examines the practicable alternativesand begins a more detailed analysis to determine which alternative is least damaging on theaquatic environment. The requirement for this analysis is found within 40 CFR Part230.10(a), which states: "Except as provided under section 404 (b)(2), no discharge ofdredged or fill material shall be permitted if there is a practicable alternative to the proposeddischarge which would have less adverse impact on the aquatic ecosystem, so long as thealternative does not have other significant adverse environmental consequences." Theanalysis presented is an effort to assess aquatic impacts of the various alternatives to allowa fair comparison between alternatives. We understand that Geographic InformationSystems (GIS) and Data Management Tasks were completed using the MS AccessGeoDatabases and ESRI ArcGIS software (with Spatial Analyst and 3D Analyst Extensions)to ascertain impacts within the 400-acre power block, localized watersheds, andtransmission lines for all four viable alternatives. The wetland component of this approachwas further refined by conducting site visits and by utilizing the dichotomous key for theNorth Carolina Wetlands Assessment Method."

Response: Acknowledged. Informational comment, no action required.

4. Comment: "The results of this assessment found that the Marion and Robinson siteswould result in higher impacts to the aquatic environments when compared to the ShearonHarris site as presented. The same drought requirement was used at these sites as wasused at the Harris site, which provided a consistent review across alternatives. It is unclear,however, if the drought requirement used at Harris could be minimized, thus resulting inlower impacts to the aquatic environment. Since this drought requirement is used for theother alternatives, it is possible that this change could reflect different impact amounts fromthe various alternatives and may require a re-evaluation."

Response: The drought requirement used at Harris has been verified through additionalmodeling and the results are documented in revisions to TM 107. Results from the


Determination of Future Harris Reservoir Storage Requirements confirm that the volume ofstorage that is provided at the 240 MSL level will be required for the expanded HarrisReservoir to provide sufficient water for PEC to continue to reliably operate the two newunits at the Shearon Harris facility during drought conditions. The estimates of storagevolumes for the Robinson and Marion sites that would provide comparable cooling water forreliable operation during drought conditions were based on the storage volume determinedfor the Harris alternative at the 240 MSL elevation. With confirmation that expansion to the240 MSL elevation is required to provide sufficient water for the Harris alternative, nochange in assumptions is needed for the Marion and Robinson alternatives regardingdrought mitigation needs. No additional re-evaluation was undertaken for the Robinson orMarion sites based on no change in drought requirement demonstrated for the Harris site.

5. Comment: "The two remaining alternatives, Brunswick and Harris, were carried forward foradditional study because their aquatic impacts were somewhat comparable. As you areaware, in order to fully satisfy our requirements relative to the 404 (b) (1) Guidelines, wemust describe and compare the loss of aquatic function(s) associated with the flooding ofexisting streams and wetlands (Harris alternative) vs. the loss of aquatic function, includinghabitat loss associated with the removal of mature trees (Brunswick alternative) within anexisting wetland. We acknowledge that the magnitude of loss between the two alternativesis different; however, we believe that the flooding of existing wetlands and streams couldresult in greater functional loss than the removal of trees from an existing forested wetland.Accordingly, the EIS must adequately describe both the magnitude of loss associated witheach of the alternatives (in acres and feet) as well as the expected loss (or changes) ofaquatic function associated with each. In addition the document must adequately describepracticable actions that further minimize these impacts. Given that significant functionaldifferences exist between the Brunswick and Harris alternatives, and that PEC has notadequately demonstrated that 240 MSL is the minimum practicable pool level, we concurwith EPA and cannot agree that the Harris alternative is the least environmentally damagingpracticable alternative."

Response: Additional evaluation has been undertaken to better describe existing wetlandand stream function and anticipated functional changes resulting from actions associatedwith the Harris and Brunswick alternatives. The methods and results of this functionalassessment are presented in the Aquatic Resource Functional Assessment (ARFA)document and the results are summarized in the appropriate sections of the revisedAlternatives Analysis document, which are attached with this response. The revisedAlternatives Analysis document describes the magnitude of loss associated with each of thealternatives, based on best information available. The expected changes in aquatic functionfor the Harris and Brunswick alternatives, as evaluated in the ARFA document, aresummarized in the revised Alternatives Analysis document. PEC anticipates that theadditional evaluation and clarification provided by the revised TM 107 and AlternativesAnalysis documents and ARFA document will provide the Corps and EPA with theinformation needed to find that the Harris alternative is the least environmentally damagingpracticable alternative.

6. Comment: " ' The topic of water quality, page 27 of the Alternatives revl, finds that theHarris alternative will have no adverse consequence on water quality and that all state waterquality permits will be in compliance. However, the results of water quality modeling studiesfor Harris Lake have not been approved by the North Carolina Department of Environment


and Natural Resources (NCDENR) which makes the finding of 'no consequence' premature.Also, since the amount of potential increase in elevation of Harris Lake is still uncertain,model results should clearly disclose the elevation of the lake used and discuss whether alower lake level would change the water quality expectations. Since minimizing the lakelevel increase is still a possibility and would affect the overall dilution potential, water qualityexpectations might be uncertain. Additional coordination with state and federal agencies onwater quality should continue."

Response: A re-evaluation of required lake level elevation was undertaken as reported inthe attached revised TM 107, with results supporting the need for expansion to the 240-footelevation. In-stream flow studies are currently underway to assess aquatic resourceprotection schemes associated with the withdrawal of water from the Cape Fear River andthe implementation of prescribed releases to Buckhorn Creek. These studies willincorporate hydrologic modeling to identify operating scenarios consistent with aquaticresource protection needs. The in-stream flow studies will be completed in 2011 in supportof the Clean Water Act Section 404/401 permit application. When compared with theBrunswick alternative, water quality impacts associated with the preferred Harris alternativewill not be greater, and are actually likely to be less when the potential for salt waterintrusion into groundwater sources near Brunswick is considered.

7. Comment: "On page 28 of the Alternatives revl, flood control, storm, and wave impacts arediscussed and the Brunswick alternative is listed as having the potential for an adverseimpact during extreme storm events, but not during normal weather conditions. Thisstatement is based on the elevation of the current facility, 20 MSL, and the elevation of themaximum storm of 22 MSL. Current flood control levees and waterproofed buildingsalleviate the potential for flood damage due to this 2 foot elevation difference. CurrentNEPA requirements call for an assessment of climate change and the potential for sea levelrise. It is unclear if this requirement was incorporated within this evaluation. If it was not,please describe and re-evaluate these topics because it appears that sea level rise mayhave major implications to this alternative. The climate assessment should also beextended to the other viable alternatives."

Response: Climate change and sea level rise were not previously considered inAlternatives revl. Appropriate sections of the Alternatives Analysis document (SectionsIV.A.5 and IV.A.6) have been revised to provide an overview of generally accepted effectsthat predicted climate change and sea level rise may have on the Harris and Brunswickalternatives, and the additional measures that have been considered for planning for theseeffects.

8. Comment: "Page 30 describes expected changes to baseflow from each alternative. Asyou are aware, there is an on-going instream flow study to determine future releases fromHarris dam into Buckhorn Creek if the Harris alternative is permitted. The NCDENR hasindicated the results of this study will require a minimum flow release into Buckhorn Creek inaddition to a prescribed release schedule based on percentage of inflow. Current waterrelease regulations on Harris dam do not require a minimum flow release, or even astructured release schedule which might benefit existing ecological features. This could beconsidered a beneficial effect with this alternative; however it is not discussed within thisdocument. NEPA and the 404(b)(1) analysis allows for the discussion of positive influences


that may be incurred from a component of an alternative. Please address this, and anyadditional positive impacts associated with other alternatives."

Response: An instream flow study is currently being performed on Buckhorn Creek. Theresults of this study may indicate that a minimum release is required to support aquatic lifein the creek. Raising the reservoir operating level would provide a mechanism to provide aminimum flow since water could be withdrawn from the Cape Fear River, stored in HarrisReservoir, and released during drought periods when inflows from the watershed below theMain Dam are minimal. This would provide a positive benefit to aquatic life in BuckhornCreek.

Section IV.A.8 of the Alternatives Analysis document has been revised to incorporate thebeneficial effects of a minimum flow release at Harris dam. Appropriate sections of theAlternatives Analysis document (Sections IV.A.4 through .6, and IV.B.1 and .4) have beenrevised to provide the additional positive impacts associated with either the Harris orBrunswick alternative that are identified through the wetland and stream functionalassessment. Other sections of the Alternatives Analysis document (Sections IV.C.2 andIV.C.3) have been revised to provide the additional positive impacts.

9. Comment: "Within the topic of special aquatic sites on pages 32-35 and again on page 37,the re-establishment of marsh wetlands along the proposed flooded fringe area of HarrisLake is discussed as a potential mitigation measure. We have surveyed other CorpsDistricts within the southeast to see whether any other District has approved of the use ofnewly formed wetlands as compensatory mitigation for flooding similar features. To date,we are unable to find a previous circumstance where this was successfully used and theDistricts were not in favor of this type of passive approach to mitigation. Moreover,operations of the proposed reactors would prohibit PEC from providing these newly-createdwetlands with the level of protection that would be expected for wetlands used ascompensatory mitigation. As stated earlier, flooding a wetland is a loss of waters. Becauseof this, we are unable to agree that flooding is both an impact and yet self-mitigating."

Response: The intent of the text as presented in Alternatives revl was not to discusscompensatory mitigation requirements, which is understood to be a consideration only afterthe LEDPA has been determined and practicable avoidance and minimization efforts for theLEDPA have been adequately addressed. The intent of the discussion of special aquaticsites on pages 32-35 and habitat for fish and other aquatic organisms on page 37 was toidentify additional considerations in evaluating the overall impact of inundating the existingnon-tidal freshwater marsh wetlands. As originally acknowledged on page 37, although notquantifiable at this time in terms of extent or timing of establishment, non-tidal freshwatermarsh wetland features similar to those being inundated are expected to re-establish wheresuitable conditions will exist in and surrounding the new pool, just as the existing wetlandsformed following construction and filling of the current reservoir and represent, at least inpart, only a temporary loss of aquatic habitat.

The ARFA (Section 4.3.1) provides a summary documenting the relatively rapidestablishment of non-tidal freshwater marsh wetlands within and along the fringes of thepool of Harris Reservoir as documented in annual monitoring reports for the period followingestablishment of the existing reservoir. The ARFA (Section 4.3.4) also providesdocumentation for recent reservoir fluctuations to approximately 7 feet below the 220-footnormal pool elevation, and summarizes data from the revised TM 107 that indicates that the


new normal pool level is expected to remain between 237 and 240 feet most of the time,with pool level dropping below 234 feet (6 feet below the normal pool level) infrequentlyduring drought conditions. Based on the relatively high function identified in the non-tidalmarsh wetlands occurring below the 220-foot normal pool level, the recent fluctuation ofapproximately 7 feet below the normal pool level does not appear to have adverselyaffected these wetlands. The fluctuations expected to occur at the new operating level arenot expected to adversely affect wetlands that may become established in a similar zone.Documentation for the rapid establishment of the non-native hydrilla within Harris Reservoiris also summarized in ARFA Section 4.3.1. Hydrilla is presently dominant or co-dominant inmuch of the non-tidal freshwater marsh acreage included as impact from flooding. Hydrillawill likely reestablish itself once the lake level reaches the new elevation, and may be ableto keep pace with the gradual rise of the pool elevation as the expanded reservoir fills.

Additional evaluation of the functions of the Harris Reservoir wetlands that will be inundatedare provided in the ARFA document and the appropriate sections of the AlternativesAnalysis document (Sections IV.A and IV.B) have been revised to include this information.Compensatory mitigation is understood to be required for unavoidable impacts resultingfrom the alternative determined to be the LEDPA after practicable avoidance andminimization efforts have been demonstrated. A compensatory mitigation plan will bedeveloped after the LEDPA has been determined and mitigation requirements determinedfor the unavoidable impacts.

10. Comment: "We can concur that the existing Harris dam is a structure that would affect andsever the biological connection to downstream ecosystems. It should be a factor whenweighing this alternative. However, we cannot concur with some of the other functionalchanges (on page 34) that the applicant expects to occur by raising Harris Lake. Therefore,we ask that PEC provide further explanation or reference the literature supporting theclaims for:

1) the lower aquatic functional value on intermittent streams and how this affects theproposal.2) the upslope migration of aquatic life when gradual flooding occurs (as listed within 3 ormore functional bullets).3) the shifting ephemeral/intermittent/perennial continuum and the conclusions reachedwithin the document.4) the watershed size supporting an intermittent stream and how this relates to the Harrisalternative.5) please expand to include functional losses expected by flooding wetlands."

Response: Clarification is provided in the ARFA document as well as revisions to theappropriate sections of the Alternatives Analysis document (Sections IV.A and IV.B) for thefunctions of existing stream types and expected functional changes that were not previouslyclearly described. Citations are provided in these documents for the sources of theinformation presented. Additional clarification is provided below for the specific comments:

1) Statements regarding intermittent streams generally having lower functional valuehave been clarified in the revised Alternatives Analysis document. The generalcondition of the intermittent streams affected by project alternatives is discussed in the


ARFA to provide a basis for discussions on expected functional changes resulting fromthe proposed action.

2) The upstream migration of aquatic life, where suitable conditions allow, has beenidentified as a trend by the North Carolina Department of Water Quality (DWQ) invarious documents. This trend is summarized in "Stream Mitigation Requirements andthe 401 Water Quality Certification and Isolated Wetland Programs: Proposed changesin internal DWQ policy" (DWQ 2008):

Intermittent stream segments have a much more even mix of terrestrialand aquatic species, with the composition shifting as the water table risesabove the stream bed or falls below it. When the water table is above theelevation of the stream bed the stream is wet and short-lived aquaticspecies, such as amphipods, isopods, winter stoneflies, diving beetles,and various dipteran (fly) larvae, dominate the community. Most of theseaquatic organisms are also found downstream in the perennial reachessince only a few species (e.g. the dipteran Dasyhela and the larvae of theaquatic beetle Helichus) live only in the intermittent segments. Theseobservations are similar to those of Boulton and Lake (1992); del Rosarioand Resh (2000); and Feminella (1996) who found that rather than beingdiscrete communities, biota in ephemeral, intermittent and perennialsegments mostly are distributed along a gradient - the more tolerant or.drought resistant the species, the further up theEphemeral/Intermittent/Perennial (E/I/P) continuum it can be found. Thiscommunity continuum shifts up and down the stream depending on theseason and the wetness or dryness of the year .... Species livingdownstream in perennial reaches include nearly all the species found inintermittent segments, plus a suite of species that require water yeararound to complete their life cycles. These groups include mayflies,stoneflies (non-winter), caddisflies, dobsonflies, dragonflies, damselflies,some beetles (riffle beetles and water pennies), most mollusks, larvalsalamanders and fish.

3) The statements regarding the shifting of the perennial, intermittent, ephemeralcontinuum were intended to describe the inundation of the lower reaches of intermittentstreams. Clarification has been provided in the revised Alternatives Analysis documentas well as the ARFA. In general, within a zone located at and near the new reservoirpool level, perennial waters associated with the new pool elevation of the lake areexpected to partially mimic lower perennial stream systems in the more confined valleytypes found along the shoreline of Harris Lake. The existing intermittent channelreaches influenced by the presence of perennial waters are expected to experience ashift from intermittent stream-based aquatic life to aquatic life more consistent withperennial water bodies. As described in DWQ's Methodology for Identification ofIntermittent and Perennial Streams and Their Origins, Version 4 (2010), the NorthCarolina stream definitions do not require water to be flowing, but only present to meetthe definition of intermittent or perennial flow for regulatory purposes. This documentalso indicates that within the regulatory framework an intermittent or perennial steamorigin is defined as a specific location in a stream, but further states that "in most cases,stream origins usually occur as transition zones in which the location and length of thezone is subject to fluctuations in groundwater levels and precipitation."


4) The watershed size supporting intermittent streams was based on the 90th percentilefor minimum area required in NC to form an intermittent stream in the Triassic Basin, asreported in a presentation by Dr. James Gregory (Professor Emeritus, North CarolinaState University Department of Forestry & Environmental Resources). This informationhas been updated in the ARFA and revised Alternatives Analysis using informationavailable through DWQ (Mapping Headwater Streams: Intermittent and PerennialHeadwater Stream Model Development and Spatial Application, 2008), which indicatesthat in the Triassic Basin of North Carolina, contributing watershed size for intermittentstreams evaluated ranged from a minimum of 0.1 acre to a maximum of 16.51 acres,with the 90th percentile reported as 11.87 acres. The intent of presenting watershed sizewas to indicate that intermittent streams were understood to require less contributingwatershed than perennial streams and that intermittent stream function could beexpected in relatively small watersheds. Additional information on intermittent streamfunction is presented in the ARFA document which is attached to this response.

5) A functional assessment was undertaken for wetlands and streams affected by theHarris and Brunswick alternatives to identify the functional changes that can beexpected from inundation as well as other project-related impacts. The results areprovided in the ARFA and summarized in Sections IV.A and IV.B of the revisedAlternatives Analysis document, which are attached to this response.

11. Comment: "There is an appearance of contradictory conclusions between the ER revl andthe current Alternatives rev1 at the Brunswick site with respect to impingement andentrainment of aquatic species and impacts to federally listed species. For example, the ERrevl (page 9-69) concludes that the impingement of fish, both adult and larval, would beminimal due to the small additional volume of water needed and the deepwater location ofthe intake. It also states that the operation of additional reactors would not adversely affectlisted species. However, the Alternatives revl states that an increase in entrainment andimpingement makes Brunswick less attractive an alternative (page 36). This discussion isextended to impacts to federally listed species which finds that increased impingement ratesmight increase the incidental take of listed turtles, and may also pertain to essential fishhabitat. The differences between documents may be due to the Alternatives revl reflectingthe most up-to-date information on the project. However, we need a clear evaluation of allimpacts associated with the need for additional cooling water."

Response: These are not contradictory conclusions. Impingement and entrainmentcriteria can be met by the addition of two new units at Brunswick, but there would be anincremental impingement and entrainment impact that would be greater than with the Harrissite due to the estuarine environment present at the Brunswick site. Appropriate sections ofthe Alternatives Analysis document (Sections IV.B.2 and IV.B.4) have been revised toprovide additional clarification regarding anticipated entrainment and impingement concernsresulting from increased flow through the intake canal.

The Brunswick site currently operates two units with once through cooling. This coolingwater is withdrawn from the Cape Fear River Estuary, provides condenser cooling capacityto the existing units, and is then discharged to the Atlantic Ocean via a 6-mile longdischarge canal. Current velocity in the intake canal, with the existing units, isapproximately 0.6 feet per second (Brunswick ER Section 3.1.2.1). The two added unitswould use closed cycle cooling, which will require less water flow than once through cooling,but will result in an overall greater volume of water being necessary for cooling the two


existing and the two new units. The increased volume of cooling water will require anincrease in the velocity of water being pumped through the intake canal. The increase inwater flow required as a result of the addition of the closed cycle cooling system, thoughnominal in comparison to once through cooling systems, could cumulatively increase theentrainment and impingement of aquatic organisms. The Phase II rules of 316(b)regulations require that power plants reduce impingement by 80 to 95 percent fromuncontrolled levels and reduce entrainment by 60 to 90 percent from uncontrolled levels.The design of the fish diversion structure was engineered for the existing two operatingunits only. Based on the additional stressor contributed by the presence of an invasivespecies of macroalgae, the make-up water for two additional units could challenge theintegrity of the diversion structure resulting in damaged diversion screens and extensivemaintenance activities.

The marine algae Gracillaria vermiculophylla is a non-native species introduced fromSoutheast Asia that is very prevalent in the Cape Fear River estuary. This invasive specieshas been identified as a major fouling organism on the Brunswick Nuclear Power Plant'scooling water and diversion and intake screens (COLA ER Section 9.3.2.2.2.5). Thismacroalgae currently causes significant screen fouling issues at the entrance to the intakecanal and has caused blow-outs of the diversion structures when too much of the materialhas accumulated. Repairs are completed as quickly as possible. However, past data haveindicated the temporary openings provide entry points for larger aquatic organisms includingendangered and threatened species such as loggerhead, green, and Kemp's ridley seaturtles. In addition to the possibility of increased impingement rates, this increases the riskof increased incidental takes of sea turtles. The National Marine Fisheries Service (NMFS)-Southeast Region issued their Biological Opinion regarding the operation of the existingBrunswick site on January 20, 2000. This biological opinion was based on their review ofthe cooling water intake system at the Brunswick site for the next 20 years. A newbiological opinion from NMFS would be required to formally document the effect onprotected sea turtle and shortnose sturgeon if additional cooling water capacity is requiredbased on additional power plants.

The current NPDES permit for the Brunswick site (NC0007064) limits cooling water flows to922 cfs/unit over the December to March period and 1,105 cfs/unit over the April toNovember period, with the stipulation that one unit may increase its flow to 1,230 cfs duringthe months of July, August, and September. These NPDES permit limits translate into two-unit flows of 1,844 cfs, 2,210 cfs, and 2,335 cfs, respectively. These reduced flows in thewinter months are necessary for the additional reductions of the entrainment losses offinfish larvae, particularly winter-spawning species. The additional requirement of 134 cfsfor the two new units would result in an increase of water flow in the intake canal, whichwould require a revised NPDES permit be applied for by PEC.

12. Comment: "Please include a map showing all transmission line routes and impacts toenvironmental features (including federal property) for the two alternatives. Please ensurethat impacts from all expected line routes are included. We realize that functional impactsto forested wetlands from transmission lines are a major component with these alternatives.Because of this, please continue to evaluate alternative means of line location to minimizeimpacts. For example, co-locating lines on existing poles could reduce a substantial amountof aquatic impacts. Document all attempts at minimizing impacts and list the reasons why,or why not, a particular minimization attempt is viable."


Response: Figures will be made available for review in Progress Energy-provided readingrooms that depict the preliminary transmission line routes that were evaluated as well asenvironmental features that were identified and considered in the Alternatives Analysis.Environmental features on the figures include NCWAM wetland types, surface waterfeatures, occurrences of federally protected species, federally-owned lands, state-ownedlands, conservation lands, and Significant Natural Heritage Areas. Given the conceptualnature of the project at the alternatives evaluation stage, detailed routing and design oftransmission has not been prepared for either alternative. The transmission impactevaluation was based on the likely routes and corridors that would be used to add neededtransmission capacity, and the use of standard PEC procedures for siting and routingtransmission was assumed. These procedures include incremental widening of existingtransmission corridors where possible, avoidance of fill in wetlands, and minimization ofimpacts from stream and wetland crossings.

13. Comment: "We understand that the State Historic Preservation Officer (SHPO) is engagedfor coordination on issues related to National Historic Preservation Act within the Area ofPotential Effect on the Harris site. This includes the 400-acre site, the area within theexpanded reservoir site, and the make-up water line. To comply with section 404 of theClean Water Act, there is a possibility that coordination with the SHPO will also be requiredon areas not included within the NRC's license area, but within the 404 permit area. Theseareas might included but not be limited to: transmission corridors, areas indicated forroadway construction/improvements, etc."

Response: As noted in PEC's April 17, 2009 letter to the SHPO transmitting theManagement Summary for the Phase I Archaeological Survey of the potential reservoirexpansion:

"Although a final decision has not been made to proceed with new plantconstruction at the Harris site, Progress Energy will notify your office as additionsto the APE are needed for potential construction areas, roads and transmissionlines, etc. We will seek your concurrence with the revised definitions of the APE,and will complete the required Phase I archaeological and historic resourcessurveys, Phase 11 evaluations (where indicated), and the Phase III mitigation ofadverse effects (if needed). Progress Energy will continue to conduct all work inconsultation and compliance with the North Carolina Office of State Archaeology,in keeping with the Department of Interior standards."

14. Comment: "Please provide a breakdown of impacts for all major components of thepreferred alternative. Table 4 of the Alternatives revl shows a partial breakdown, butanticipated impact amounts for additional components are needed. Examples wouldinclude items such as interchange construction, roadway improvements, blowdown lines,rail line extensions, transmission lines, staging areas, drinking and waste water treatmentplant upgrades, make-up water lines, power block impacts, drought mitigation measures(i.e. lake elevation increase), water make-up lines, blasting, and re-establishment of parkand other public facilities."

Response: An evaluation of impacts for major components of the preferred alternative areprovided in the Harris ER and in subsequent RAI responses submitted to the NRC. Chapter4 of the ER outlines impacts associated with the proposed expansion of transmission lines


to support the operation of HAR Units 2 and 3 (HAR2 and HAR3). Specifically, ER Sections4.1.2.2, 4.3.1.5, and 4.3.2.5 discuss impacts related to the construction of the expandedtransmission line. Wetland and surface water impacts are specifically discussed in Section4.3.1.5 of the ER.

A breakdown of other impacts related to project components such as roadways, blowdownlines, and staging areas was provided to the NRC in Progress Energy's letter: Response toUSACE Requests for Additional Information Regarding the Environmental Review, datedFebruary 12, 2009. Specifically, Progress Energy's response to USACE 12, documented inPGN RAI ID #: H-362, including Attachment 1A, identifies disturbed areas (including lakesand streams) resulting from construction activities. Wetlands and streams that are presentin the project area are described in Section 2.3 of the ER.

A detailed breakdown of impacts for all major components is not available for the otheralternatives evaluated. The information for the preferred alternative was not provided in theAlternatives Analysis (Revision 1) to keep the comparison among alternatives consistent.

15. Comment: "Also, please expand the no action alternative to describe the project goingforward without a 404 permit (i.e. no impacts to waters of the U.S.) even if licensed by theNuclear Regulatory Commission. Finally, please provide a report summary showingstructural integrity of the existing Harris dam with respect to the potential for expanding thenormal pool."

Response: Section III.B.1 of the Alternatives document has been revised to provideinformation for a no-action alternative for the Harris site. This no-action alternative wouldnot require a 404 permit by maintaining the current 220-foot NGVD29 operating level ofHarris Reservoir, but would instead supplement cooling water supply by withdrawals fromthe Cape Fear River. Hydrologic modeling presented in the revised TM 107 demonstratedthat this scenario provided an insufficient water supply for the facility for more than 40percent of the 80-year simulation period, and as such does not meet PEC's stated purposeand need and is not a viable alternative. Times of drought are typically times of peakenergy demand in PEC's service territory. Therefore, losing generating capacity during adrought is inconsistent with PEC's business objectives, inconsistent with meeting goals forreliable service, and potentially results in life-threatening service interruptions. The no-reservoir option for the Harris alternative has been dropped from further consideration.

Although the physical impact caused by inundating wetlands and streams is considered animpact by the USACE under regulatory guidelines for permitting and mitigation purposes,inundation does not result in a complete loss of aquatic function but rather represents aconversion of one aquatic type to another that also provides aquatic function. The ARFAdocument that has been prepared and is attached to this response summarizes thefunctional changes that are expected to occur as a result of reservoir expansion andidentifies the aquatic functions that will be present within the expanded reservoir.

TM 107 has been revised to include a summary showing structural integrity of the existingHarris dam with respect to the potential for expanding the normal pool. The analyses citedby TM 107 indicate that dam safety is not an issue for reservoirs at least as high as 245-feetNVGD29.


16. Comment: "Please realize with the information provided to date, we are unable to concurthat the Harris site has the least amount of aquatic impacts of the alternatives considered.PEC's development of information addressing these comments and those presented byEPA will help ascertain the alternative with the least aquatic impacts."

Response: PEC has reviewed the comments and requests for additional informationreceived from the Corps and EPA on the Alternatives Analysis rev1 and TM 107 documents.PEC is herewith providing additional information on the Harris and Brunswick alternativesfor further consideration by the Corps and EPA in evaluating the two alternatives. Theseadditional efforts are summarized in the responses provided to the Corps and EPAcomments and are presented in the revised TM 107 and Alternatives Analysis documentsand Aquatic Resources Functional Assessment document that are attached to thisresponse. PEC believes that the Harris site has the least overall impact on the aquaticenvironment and no other significant adverse environmental consequences, and should bethe least environmentally damaging practicable alternative.

EPA Comments:

17. Comment: "Progress Energy Carolinas (PEC) is proposing to construct two additionalreactor units at the Shearon Harris Nuclear Power Plant in Wake County, North Carolina(NC). The project, as proposed includes the construction of an intake structure and pipelineto supply water from the Cape Fear River to Harris Reservoir, placement of a seconddischarge structure within Harris Lake, upgrades to transmission lines and roads andincreasing in the normal pool elevation of Harris Lake from 220 feet to 240 feet mean sealevel (MSL). The Environmental Protection Agency (EPA) has reviewed the AlternativesAnalysis (Revision 1) and the Technical Memorandum (Determination of Harris ReservoirStorage Requirement) documents. It is our understanding that Revision 1 of theAlternatives Analysis document was revised in response to comments from the U.S. ArmyCorps of Engineers (Corps). We have also reviewed Enclosure 2 which provides aresponse to the Corps' comments. The Technical Memorandum (TM) was prepared forPEC by CH2M Hill to respond in greater detail to the concern raised in the Corps' commentsconcerning the justification of raising Harris Lake level from 220 feet to 240 feet MSL."

Response: Acknowledged. Responses to the EPA's specific comments are providedherein.

TIVI 107 (Determination of Harris Reservoir Storage Requirement)

18. Comment: "PEC is proposing to raise the level of the cooling reservoir (Harris Lake) at theShearon Harris facility from its current elevation of 220 feet to 240 feet MSL as part of theexpansion of the current facility to provide sufficient cooling water for the two new reactorsin the event of an extreme extended drought. The proposed increase in elevation will floodapproximately 500 acres of wetlands and 24.4 miles of streams. [There is some discrepancyas to what actual level the current dam, as designed, can safely accommodate. Differentlevels are cited in the material provided, i.e., 239.1, 240, 250. Since the level of 240 is mostfrequently cited, for the purpose of this discussion, we are assuming this to be the both thelevel that can be safely accommodated by the current dam and the applicant preferred level,but this issue needs to be resolved.]"


Response: As described in TMEM-107 Rev 3, a probable maximum hurricane (PMH)evaluation was performed to support the HAR Final Safety Analysis Report (FSAR). Thisanalysis determined that 240 feet NGVD29 is the highest level that can be safelymaintained under extreme conditions. The safety of the dam was also evaluated in supportof the FSAR. Reviews of the Main Dam slope protection and slope stability indicate that thedam can support operating levels of at least 245 feet NGVD29.

240 feet NGVD is also the applicant-preferred level based on an evaluation of water supplyconstraints. TMEM-1 07 demonstrates that an operating level of 240 feet NGVD29 isrequired to meet the purpose and need of the project, providing continued reliable powergeneration from the three units while minimizing impacts to water resources in the CapeFear River Basin.

19. Comment: "After reviewing both the TM and the responses to the Corps in the Enclosure2, we continue to have concerns with the proposal to raise the level of Harris Lake to 240.This process seems to have been conducted in reverse, in that 240 was selected becausethis is the level the current dam can safely accommodate and Shearon Harris owns the landto the 243 MSL contour. There was no discussion of beginning this process from the otherend and determining what would be the minimum rise in cooling lake elevation that would bethe least environmentally damaging practicable alternative. EPA is concerned with the verylarge aquatic environmental impacts (loss of waters) associated with raising the lake to the240 contour level."

Response: Acknowledged. Responses to additional questions and concerns on TM 107are provided to comments numbered 20 through 25.

20. Comment: "The lake elevation rise appears to be only needed in the case of severedrought, i.e., 220 would be sufficient except in a severe extended drought situation. Fromthe information presented, even the 240 level would not be sufficient in a very severeextended drought. Although some extrapolations can be made, there was no discussion ofwhat raising the lake to 225, 230, 235, etc. would provide as far as operation in drought andthe environmental impacts associated with these levels. There needs to be a comparisonand in depth discussion as to what would be provided by levels other than 240 and theassociated environmental impacts."

Response: The revised TMEM-107 documents the impacts on reservoir level andgeneration reliability for a "no action alternative," which specified an operation level of 220feet NGVD29. Results show that the units would need to shut down due to lack of coolingfor at least 40 percent of the time.

TMEM-107 also presents a comparison of reservoir levels for operating levels of 240, 238,and 236 feet NGVD29.

A 240-foot NGVD29 operating level met the objective of providing a reliable source ofpower at all times. The maximum drop in reservoir level was an elevation of 226.6 feetNGVD29, which is 2.4 feet below the reserve level. Water was withdrawn from thereserve pool for 343 days or approximately 1.17 percent of the 80-year evaluationperiod. Occasional brief withdrawals from the reserve pool are acceptable since onepurpose of the reserve pool is to provide a cooling water supply in the case of extremeconditions or unforeseen conditions. The period from May 1988 through April 1989 was


one such period where rainfall was limited and flow in the Cape Fear River wasfrequently less than 600 cfs. During this period, water was withdrawn for 207 of 365days or 56.7 percent of the time of withdrawal from the reserve pool.

* A 238-foot NGVD29 operating level does not meet the reliability criteria. In the modelrun, shutdown was required twice during late 1988 and early 1989. The first occurrencebegan on September 24, 1988 and lasted for 39 days. The reservoir level fell to 223.6feet NGVD29, which is below the 224-foot NGVD29 minimum level required byengineering design. The second shutdown began on December 27, 1989 and continuedfor 11 days. The second shutdown would have occurred when power demands werepotentially very high due to use for heating.

The operating level of 238 feet NGVD29 would require withdrawals from the reservepool for approximately 939 days over the 80-year evaluation period or 3.2 percent of thetime. For the same extreme drought period from May 1988 through April 1989, waterwas withdrawn from the reserve pool for 249 of 365 days or 68.2 percent of the time.

" A 236-foot NGVD29 operating level would not meet the reliable generation of powercriteria. In this scenario, the reservoir level fell to 220.3 feet NGVD29, requiring the plantto shut down. For this scenario, the plant would be shut down for 231 days during theperiod from July 1988 through February 1989. Four other shutdowns of shorter durationwere predicted to occur in the period from 1930 through 2009. These shutdowns wouldoccur during the summer when power demands could potentially be very high due touse cooling requirements and during the winter when power demands could potentiallybe very high due to use for heating.

A 236 foot NGVD29 operating level increased the number of days the reserve pool wasused to 1,986 or 6.8 percent of the time over the 80-year evaluation period. For thesame extreme drought period from May 1988 -through April 1989, water was withdrawnfrom the reserve pool for 324 of 365 days or 88.8 percent of the time.

A sensitivity analysis was performed to determine the impacts to jurisdictional wetlandsassociated with reservoir levels of 240, 238, and 236 feet NGVD29. The results showed thatapproximately 565.2 acres or 91.3 percent of the total wetland impacts occur if the reservoiris raised above 224 feet NGVD29. Additional impacts occur gradually at higher elevations.Approximately 614.2 acres of wetlands may be impacted if the reservoir operating level is236 feet NGVD29. An additional increase of 0.5 percent (2.8 acres) of wetland impacts isassociated with a reservoir level of 238 feet NGVD29. Approximately 4.9 acres of additionalwetland impacts, or an increase of 0.8 percent, is associated with a reservoir level of 240feet NGVD29.

21. Comment: "The Western Wake Partners' new Water Reclamation Facility (WRF) will bereleasing an estimated 25 million gallons per day (mgd) by 2020 and 38 mgd by 2050somewhere (most likely the Cape Fear River). How have these numbers been incorporatedinto the modeling of water in the Cape Fear? The TM states the new reactors will require63 cubic feet per second (cfs) or 40.7 mgd for replacement water for evaporation from thecooling towers. We understand Shearon Harris has investigated the possibility of havingthe WRF water discharged directly to Harris Lake, so less water would need to be pumpedfrom the Cape Fear River but this would also necessitate raising the lake level and wouldhave similar flooding impacts as withdrawing the water from the Cape Fear. We are awarethat the current NC Department of Environment and Natural Resources approved discharge


point for the WRF water may be below Buckhorn dam but it appears there is still someflexibility in the location of the discharge point. Could it be moved to accommodate theShearon Harris withdrawal needs from the Cape Fear or could Shearon Harris have awithdrawal pump below the WRF discharge point? These issues concerning the impact ofthe WRF discharge into the Cape Fear and how this might impact the ability for ShearonHarris to withdraw without the increase storage to 240 should be addressed."

Response: The Western Wake Water Reclamation Facility (WRF) is included in theanalysis as a direct discharge to the Cape Fear River. The Western Wake Partners haveevaluated the potential for discharging the effluent from the WRF to Harris Lake. However,the regulations for interbasin transfers have made this option infeasible.

The specific location of the discharge point on the Cape Fear River, above or below theproposed intake point, would not have an impact on water resources in the Cape Fear Riverbasin since the net flow as recorded at the Lillington USGS gage would be the same.

22. Comment: "We recommend the NC Division of Water Resources (NCDWR) review the TMand supporting information, including the Sargent and Lundy 2009 report, modelingassumptions, WRF input, etc., and provide their analysis of the information contained in theTM. One of the model assumptions utilizes the maximum withdrawal rates from the CapeFear based on future demands. EPA region 4 is currently finalizing Water Efficiencyguidelines. Any proposed water supply reservoir will be required to use these guidelineswhere practicable. These water efficiency measures have the ability to greatly reduce waterneeds. Although, this is not directly applicable to this project, these measures, onceapproved, should become widely used for any water supply provider (not just new reservoirprojects) and may influence future demands on the Cape Fear River."

Response: PEC has provided TMEM-107 to the NCDWR for review and has taken part indiscussions with the NCDWR regarding this analysis. The basis for the analysis is theNCDWR's Cape Fear River Basin Hydrologic Model (CFRBHM), including their predictionsof future demands. While the U.S. EPA's Water Efficiency guidelines may revise future usepredictions, the analysis utilizes the best information on demands in the Cape Fear Riverthat is currently available.

23. Comment: "The TM states the proposed project will provide the applicant with the ability tooperate with reduced withdrawals from the Cape Fear during drought conditions andthereby minimize adverse impacts to aquatic life. This statement fails to address the verylarge impacts to aquatic life that will occur from flooding 500 acres of wetlands and 24.4miles of streams. We do not believe this project to be a net gain for aquatic life."

Response: This statement has been revised to clarify that reducing withdrawals from theCape Fear River during drought periods will minimize impacts to aquatic life in the CapeFear River.

It is recognized that the project will impact existing wetlands around Harris Reservoir.However, an operating level of 240 feet NGVD29 is required to meet the objectives of theproject. A review of the wetland delineations was performed to determine the impacts tojurisdictional wetlands associated with reservoir levels of 240, 238, and 236 feet NGVD29.The results showed that approximately 565.2 acres, or 91.3 percent, of the total wetland


impacts occur if the reservoir is raised above 224 feet NGVD29. Less than 1 percent of theimpacts occur within the range of 236 to 240 feet NGVD29.

24. Comment: "The TM discusses the use of NCDWR's model for the Cape Fear River. Thediscussion states modeled inflows are primarily due to rainfall runoff and point discharges.There is no mention of the future WRF discharge which will be a significant inflow andshould be considered. Although the WRF project has not yet been permitted, the finalenvironmental impact statement (EIS) was released in December 2009 and the WRF isscheduled to be operational as of the third quarter of 2013. Although this project has notyet been permitted, we believe the WRF potential inflow to the Cape Fear should beconsidered in the modeling for the Shearon Harris project. To be able to include the yearsfrom October 2004 to December 2008 (where NCDWR data was not available), data wasused from the U. S. Geological Survey gage at Lillington to be able to capture the extremedrought of 2007. We believe the model should be rerun to include 2009 data which was avery wet year."

Response: The NCDWR's CFRBHM was used to evaluate the required reservoir level.The model does include a discharge from the proposed Western Wake WRF.

The modeling period in the CFRBHM was extended to December 2009 to include the recentdrought of 2007 and the wet year of 2009. The results included in the revised TMEM-1 07are based on this extended period.

25. Comment: "The last section of the TM discusses the benefits from the increased reservoirlevel, including increased shoreline and lake habitat. As we stated earlier the proposedelevation of the lake level to the 240 contour will result in the flooding of 500 acres ofwetlands and 24.4 miles of streams. EPA considers this a very significant net loss ofaquatic resources. The information reviewed to date does not provide a compellingjustification that the anticipated benefits of water supply during a severe extended droughtoutweighs the magnitude of the impacts associated with raising Harris Lake to the 240contour level."

Response: It is recognized that the project will impact existing wetlands around HarrisReservoir. However, maintaining the reservoir elevation at an operating level of 240 feetNGVD29 is required to meet the project objective of reliable power.

Alternatives Analysis

26. Comment: "The alternatives analysis evaluated eleven potential sites to fulfill the project'spurpose to develop new nuclear baseload generating capacity to supply electricity to PEC'sservice area. Of those sites, seven were eliminated during the siting study. The four sitescarried forward for further consideration were Marion, Robinson, Brunswick and Harris. Ofthese four, the Marion and Robinson sites were dropped from further evaluation becausethe alternatives analysis indicated they would have significantly higher impacts to wetlandsand streams than the applicant preferred site (Harris). There was not an alternative whichevaluated constructing the two new reactors at the Shearon Harris site but without raisingHarris Lake to the 240 contour. With the information we have been presented to date, webelieve an expansion alternative operating at a 220 level or somewhere less than 240 to be


a viable alternative and should be evaluated. The Brunswick and Harris sites were carriedforward for a more detailed evaluation."

Response: Section III.B.1 of the Alternatives document has been revised to provideinformation for a no-action alternative for the Harris site. This no-action alternative wouldnot require a 404 permit by maintaining the current 220-foot NGVD29 operating level ofHarris Reservoir, but would instead supplement cooling water supply by withdrawals fromthe Cape Fear River. Hydrologic modeling presented in the revised TIVI 107 demonstratedthat this scenario provided an insufficient water supply for the facility for more than 40percent of the 80-year simulation period, and as such does not meet PEC's stated purposeand need and is not a viable alternative.

TMEM-107 also provides a comparison of reservoir levels for operating levels of 240, 238,and 236 feet NGVD29, as summarized in a previous response to an EPA comment (seeresponse to Comment #20 above).

27. Comment: "The Brunswick site is located on the lower Cape Fear estuary and currentlyhas two existing nuclear reactors. Due to the water supply at the site location, a reservoir isnot required and consequently no loss of waters of the U. S. would occur from floodingimpacts. This alternative would require approximately 360 miles of transmission lines andconversion of approximately 1450 acres of wetlands from forested to herbaceous in theright of way areas. Although the Brunswick site would result in greater impacts to wetlandsthan the Harris site, it would be a conversion of wetlands from forested to herbaceous. Thetransmission lines will span streams and no direct impacts to stream channels are expected.The increase of Harris Lake from 220 to 240 would result in a loss of waters ofapproximately 500 acres of wetlands and 24.4 miles of stream due to inundation. Inaddition, there would a transmission line right of way conversion of approximately 99 acresof wetlands from forested to herbaceous associated with the Harris alternative."

Response: The acreages presented in the Alternatives Analysis Revision 1 document forthe Harris alternative were based on a GIS-based evaluation comparable to the level ofevaluation available for the other three alternatives. This was presented in this manner toprovide a more direct comparison among the four alternatives utilizing the same level ofevaluation of potential impacts. The preliminary results of the jurisdictional delineationundertaken for the Harris alternative, as provided in a footnote to Table 4 in the AlternativesAnalysis Revision 1 document, provided a more refined assessment of the potentialimpacts. The revised Alternatives Analysis document provides the updated informationfrom the jurisdictional delineation of the Harris site as well as updated information resultingfrom additional ground reconnaissance along the Brunswick transmission lines during theNCWAM evaluation in Sections III.B.3.d and III.B.3.c. Additional evaluation has beenundertaken to better describe existing wetland and stream function and anticipatedfunctional changes resulting from actions associated with the Harris and Brunswickalternatives. The methods and results of this functional assessment are presented in theAquatic Resource Functional Assessment (ARFA) document and the results aresummarized in the appropriate sections of the revised Alternatives Analysis document,which are attached with this response. The revised Alternatives Analysis documentdescribes the magnitude of loss associated with each of the alternatives, based on bestinformation available. The expected changes in aquatic function for the Harris and


Brunswick alternatives, as evaluated in the ARFA document, are summarized in the revisedAlternatives Analysis document.

28. Comment: "A Geographic Information System (GIS) desktop analysis was conducted todetermine aquatic impacts for the foursites carried forward. The Harris site is the only sitewhich has had extensive field level impact analysis. We believe the GIS level analysis wassufficient to estimate potential impacts for a rough comparison of alternatives to be able totell which alternatives should be carried further in the analysis. At this point, we think it maybe appropriated to collect more field based delineation data for the Brunswick alternative.We do not agree with the executive summary conclusion that "...the Brunswick alternativedoes not constitute an alternative demonstrating less adverse impact on the aquaticecosystem in comparison to the preferred alternative, the Harris site." Although theBrunswick site converts 1450 acres of wetlands from forested to herbaceous, the Harris sitepermanently inundates 500 acres of wetlands, 24.4 miles of streams and converts 99 acresfrom forested to herbaceous. The alternatives analysis states that most of the 24.4 miles ofstream impacts is not perennial, however information presented at the September 29, 2009,interagency review team meeting shows the breakdown to be almost evenly dividedbetween perennial and intermittent with slightly more perennial impacts. This should becorrected in the alternatives analysis."

Response: Field-based delineation data is not believed to be warranted for this alternativeanalysis due to the limited additional information that would be provided by such an effortcompared to the additional cost and time involved. The transmission line analysis is notbased on actual siting studies and undertaking the siting studies for an alternative notidentified as the preferred alternative would represent an undue burden for PEC and itsratepayers. Changes in wetland acreages obtained through a refinement of the GIS levelanalysis by field delineation once siting studies have been completed would not likely resultin substantive changes in the comparison of aquatic impacts resulting from conversion ofwetlands and streams within and upstream from the existing Harris reservoir resulting fromthe Harris alternative reservoir expansion versus the relative acreage converted fromforested to herbaceous wetlands resulting from the Brunswick alternative transmission lineupgrades. The comparison of the GIS level analysis for the Harris Reservoir expansion tothe actual delineation, as presented in Table 4 of the Alternatives Analysis (Revision 1) andfootnotes, demonstrated that the GIS level analysis provided what is believed to be areasonable approximation of the actual aquatic resource features present. The Corpsjurisdictional determination has been completed and the results are reported in Table 4 inSection III.B.3.d of the revised Alternatives Analysis document. The GIS-based estimate ofwetlands and streams for the Harris reservoir expansion is now provided in a footnote toTable 4 for comparison.

PEC is herewith providing additional information on the Harris and Brunswick alternativesfor further consideration by the Corps and EPA in evaluating the two alternatives, includingadditional information in the attached ARFA document summarizing the anticipatedmagnitude of aquatic resource impacts and anticipated. resulting changes to aquaticresource functional change. Based on this information, along with information presented inthe revised TM 107 and Alternatives Analysis documents attached to this response, PECbelieves that the Harris site has the least overall impact on the aquatic environment and noother significant adverse environmental consequences, and should be the leastenvironmentally damaging practicable alternative.


The information presented at the September 29, 2009, interagency meeting regardingbreakdown of stream impacts by perennial versus intermittent channel was based onpreliminary results of the actual field delineation at that time. The Corps jurisdictionaldetermination has been completed and the results are reported in Table 4 in SectionIII.B.3.d of the revised Alternatives Analysis document. The 24.40 miles of stream referredto in the Alternatives Analysis (Revision 1) is based on the GIS level analysis for the Harrisalternative, which was used so that a direct comparison could be made to the otheralternatives using results obtained from comparable methodology of assessment. This wasdescribed in footnotes to Table 4 and Table 6 in Alternatives Analysis (Revision 1) and inthe text in Section III.B.4. The revised Alternatives Analysis document (Revision 2) hasbeen updated to incorporate the results of the delineation, with clarification provided inSection LID (Analysis Methodology) and footnote to Table 4 (Section III.B.3.d).

29. Comment: "Based on the information we have reviewed, we believe the Brunswick site tobe a viable alternative. There are several issues associated with the Brunswick site whichwe believe require additional information to allow us to conduct a better review. Besides abetter understanding of the actual impacts, we recommend the following items beaddressed in greater detail for the Brunswick alternative:

1 . Entrainment and impingement impacts from the increased volume of cooling waterto aquatic organisms, including sea turtles. The discussion comparing the aquaticimpacts from increased cooling water flow from adding two reactors to either facilityshould be better quantified to help weigh the costs between the two facilities,including information that quantifies the current aquatic impacts of the facility, alongwith those anticipated with project impacts.

2. Because of the location of the Brunswick facility on the Cape Fear estuary, werecommend Sections 5 (Flood Control Functions) and 6 (Storm, Wave and Erosionbuffers) be expanded to provide a more thorough discussion concerning bothpotential sea level rise and hurricane impacts.

3. It would also be useful in evaluating the two alternatives to include a conceptualdiscussion of mitigation for the impacts associated with each alternative, includingconversion and flooding impacts."

Response: Additional information pursuant to 40 CFR 230 and 33 CFR 320 has beenprovided for the Brunswick site in the revised Alternatives Analysis document. Thisadditional information provides information for the EPA and Corps to more fully evaluate theimpacts associated with the Brunswick site in comparison to the Harris site.

There would be an incremental impingement and entrainment impact at the Brunswick sitethat would be greater than with the Harris site due to the estuarine environment present atthe Brunswick site. Appropriate sections of the Alternatives Analysis document (SectionsIV.B.2 and IV.B.4) have been revised to provide additional clarification regarding anticipatedentrainment and impingement concerns resulting from increase flow through the intakecanal.

Climate change and sea level rise were not previously considered in Alternatives rev1.Appropriate sections of the Alternatives Analysis document (Sections IV.A.5 and IV.A.6)have been revised to provide an overview of generally accepted effects that predicted


climate change and sea level rise may have on the Harris and Brunswick alternatives, andthe additional measures that have been considered for planning for these effects.

Compensatory mitigation is understood to be required for unavoidable impacts resultingfrom the alternative determined to be the LEDPA after practicable avoidance andminimization efforts have been demonstrated. A compensatory mitigation plan will bedeveloped after the LEDPA has been determined and mitigation requirements determinedfor the unavoidable impacts. Beneficial effects on aquatic resources and aquatic resourcefunctions resulting from conversion and flooding impacts are included in the ARFA andappropriate sections of the revised Alternatives document. PEC understands the Corps andEPA will consider beneficial effects as well as negative effects when evaluating whichalternative results in the least overall environmental impact to aquatic resources.

30. Comment: "EPA appreciates the opportunity to review and comment on the TM andAlternatives Analysis documents during the EIS development process. We recommend thealternatives issues discussed above be further addressed to provide us with a betterunderstanding of the alternatives and to enable us to provide further input in thedetermination of the least environmentally damaging practicable alternative."

Response: PEC has reviewed the comments and requests for additional informationreceived from the EPA and Corps on the Alternatives Analysis rev1 and TM 107 documents.PEC has undertaken efforts intended to provide additional information on the Harris andBrunswick alternatives for further consideration by the EPA and Corps in evaluating the twoalternatives. These additional efforts are summarized in the responses provided to the EPAand Corps comments and are provided to the EPA and Corps in revised TM 107 andAlternatives Analysis documents and Aquatic Resources Functional Assessment documentthat are attached to this response. PEC believes that the Harris site has the least overallimpact on the aquatic environment and no other significant adverse environmentalconsequences, and should be the least environmentally damaging practicable alternative.

Associated HAR COLA Revisions:

No COLA revisions have been identified associated with this response.

Attachments/Enclosures:

Attachment 1: 338884-TMEM-107 Rev 3 - Determination of Future Harris Reservoir StorageRequirements, Revision 3 [41 pages]

Attachment 2: Harris Advanced Reactor (HAR) Section 404(b)(1) Alternatives Analysis,Revision 2 [103 pages]

Attachment 3: Aquatic Resource Functional Assessment in support of the Harris AdvancedReactor 404(b)(1) Alternatives Analysis [57 pages]

shearon harris, units 2 and 3, response to u.s. army corps

Documents